3:24-cr-00002-JFA Date Filed 01/03/24 Entry Number 1 Page 1 of 6

UNITED STATES DISTRICT COURT

DISTRICT OF SOUTH CAROLINA
COLUMBIA DIVISION

LINITED STATES OF AMERICA ) CRIMINAL NO. 3:24-2

)
)
) 18 U.S.C. $ e81(aXlXC)
) 18 u.s.c. $ e82(a)(2)(A)
) 18 U.S.C. $ 1343
v ) 28 U.S.C. I 2461(c)
)
KATHY DRAWDY STEWART ) INFORMATION
)

BACKGROUND

At all times material to this Information:

1. The Defendant, KATHY DRAWDY STEWART, resided and worked in the

District of South Carolina.

2. The victim, LTC Associates, Inc ("LTC"), is a privately owned architecture firm

incorporated in the State South Carolina with headquarters in Columbia, South Carolina.

3. The Defendant, KATHY DRAWDY STEWART, was employed by LTC

beginning in 2005 and continuing through her termination in 2023.

4. Since 2009, the Defendant KATHY DRAWDY STEWART held the position of

Business Manager with LTC. In that capacity her responsibilities included managing payroll,

paying company bills, invoicing clients, and that position provided her access to company credit

cards and other similar financial accounts.

5. In executing the scheme as described below, the Defendant KATHY DRAWDY

STEWART abused her position of trust as the Business Manager to defraud LTC of funds for

personal gain.
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COUNTS 1 - 5
(Wire Fraud)

THE UNITED STATES ATTORNEY CHARGES:

6. The allegations in paragraphs 1 through 5 of this Information are realleged and

incorporated herein by reference as if set forth fully herein.

The Scheme to Defraud

7. That on or about the dates below, in the District of South Carolina, the Defendant

KATHY DRAWDY STEWART, for the purpose of executing and attempting to execute a

scheme and anifice to defraud and to obtain money or property from LTC by means of materially

false and fraudulent pretenses, representations, and promises, did knowingly transmit and cause to

be transmitted by means of wire in interstate commerce, certain writings, signs, signals, and sounds

for the purpose of executing such scheme; that is, the Defendant, KATHY DRAWDY
STEWART, did knowingly cause to be transferred to her by interstate wire funds belonging to

LTC through a scheme designed to make the transfers appear as if they were legitimate business

expenses when in truth and fact they were not.

Manner and Means o_f the Scheme

8. It was part of the scheme that as a part of the Defendant KATHY DRAWDY

STEWART's role as Business Manager she had access to LTC's First Citizen's bank account and

LTC's QuickBooks account.

9. It was further part of the scheme that the Defendant KATHY DRAWDY
STEWART made purchases on her personal American Express credit card and then compensated

herself by transferring funds from LTC's First Citizen's bank account to herself in amounts that

were unauthorized and exceeded any legitimate business expense.

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10. It was further part of the scheme that when the Defendant KATHY DRAWDY

STEWART was managing LTC's QuickBooks account, she would conceal those unauthorized

payments by coding them to appear as if they were legitimate business expenses, when in truth

and fact they were not.

ll. Through the scheme described above, the Defendant KATHY DRAWDY

STEWART fraudulently obtained at least $280,000.00 in funds from LTC from at least 2016

through May 2023.

12. On or about the dates specified below in the District of South Carolina, and

elsewhere the Defendant KATHY DRAWDY STEWART, for the purpose of executing the

scheme and artifice described above, did transmit and cause to be transmitted in interstate

commerce, by means of wire communications, the writings, signs, and signals, further described

below, on or about the dates specified:

Count Date of Wire Amount of Wire Description of Wire

1. January 2,2019 $2,000.00 Payment from LTC First Citizen's bank

account ending in 5501 to Kathy D.
Stewart American Express account
ending in2009, coded as "Distributions-
Wes Taylor" in LTC QuickBooks

2. November 17,2020 $5,000.00 Payment from LTC First Citizen's bank

account ending in 5501 to Kathy D.
Stewart American Express account
ending in2009, coded as "Split" in LTC
QuickBooks

J
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Count Date of Wire Amount of Wire Description of Wire

a
Jlune 30,2021 $5,000.00 Payment from LTC First Citizen's bank
account ending in 5501 to Kathy D.
Stewart American Express account
ending in2009, coded as "Split" in LTC
QuickBooks

4. September 19,2022 $5,000.00 Payment from LTC First Citizen's bank

account ending in 5501 to Kathy D.
Stewart American Express account
ending in 1007; coded as "Distributions-
Wes Taylor" in LTC QuickBooks

5 January 19,2023 $1,000.00 Payment from LTC First Citizen's bank

account ending in 5501 to Kathy D.
Stewart American Express account
ending in 1007; listed as "Business
Development" in LTC QuickBooks

All in violation of Title 18, United States Code, Section 1343.

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FORFEITURE

WIRE FRAUD:

Upon conviction to violate Title 18, United States Code, Section 1343 as charged in the

Information, the Defendant, KATHY DRAWDY STEWART shall forfeit to the United States

any property, real or personal, which constitutes, is traceable, or is derived from any proceeds the

Defendant obtained, directly or indirectly, as the result of such violations.

PROPERTY:

Pursuant to Title 18, United States Code, Sections 981(a)(1)(C) and 982(aX2)(A), and Title

28, United States Code, Section 2461(c), the property which is subject to forfeiture upon

conviction of the Defendant for the offenses charged in this Information includes, but is not limited

to, the following:

Proceeds/Forfeiture Judgment:

A sum of money equal to all proceeds the Defendant obtained, directly or indirectly, from
the offenses charged in the Information, that is, at least $280,000.00 in United States
currency, and all interest and proceeds traceable thereto, and./or such sum that equals all
property derived from or traceable to her violations of l8 U.S.C. $ 1343.

SUBSTITUTION OF ASSETS:

Ifany ofthe property described above as being subject to forfeiture, as a result ofany act

or omission of the Defendant:

A. Cannot be located upon the exercise of due diligence;

B. Hasbeen transferred or sold to, or deposited with, a third person;
C. Hasbeen placed beyond the jurisdiction of the Court;
D. Hasbeen substantially diminished in value; or
E. Hasbeen commingled with other property which cannot be subdivided
without difficulty;

it is the intent of the United States, pursuant to Title 21, United States Code, Section 853(p) to seek

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forfeiture of any other properff of the Defendant up to an amount equivalent to the value of the

above-described forfeitable property ;

Pursuant to Title 18, United States Code, Sections 981(aXlXC) and 982(a)(2)(A), and

Title 28, United States Code, Section 2461(c).

ADAIR F. BOROUGHS
UNITED STATES ATTORNEY

By:
Elliott No. 1

Elle E. Klein (Fed. ID No. 12941)

Assistant United States Attorneys
United States Attorney's Office
1441 Main Street, Suite 500
Columbia, SC 29201
Telephone 803 -929-3 000
Facsimile 803 -25 6-0233
Elliott. Daniel s@usdoj . gov